Search - 阿里拍卖 司法拍卖

. … [T]ime spent on the road, on the premises of properties for sale, and at the real estate broker's place of business cannot be assimilated to time spent working at the home office. ...

4 December 2007 Internal T.I. 2007-0237461I7 F- Définition d'activité de construction-- summary under Subsection 238(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 238- Subsection 238(2) construction activities included cable installation, maintenance and upgrading/primarily means over 50% The taxpayer, which had queried whether it was required to file T5018 slips for payments made to subcontractors, was engaged in the installation of cabling, both public and residential lines – and also was involved in the construction of overhead and underground cables, the installation of equipment, the maintenance and renovation of networks, the interior and exterior pre-wiring of buildings and the installation and servicing of certain products. ...

In finding that this was a prescribed prize, the Directorate stated: [T]he prize of excellence … was publicly recognized. ...

. … [T]here is no jurisprudence dealing with filling the hole in a situation such as the one under review. ...

. … [W]e cannot conclude that he is entitled to perform most or all of the duties of a minister, including, inter alia, administering most of the sacraments of the Roman Catholic Church. ...

. … [W]e cannot conclude that he is entitled to perform most or all of the duties of a minister, including, inter alia, administering most of the sacraments of the Roman Catholic Church. ...

. … [T]hey can also benefit from an offsetting deduction under paragraph 110(1)(f) so that those amounts are not taxed. ...

21 March 2005 Internal T.I. 2005-0119961I7 F- CCPC STATUS-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date effective date of transfer of shares (entailing acquisition of control) cannot precede determination of essential contract elements USco disposed of 50% of the shares of Canco to another corporation ("Holdco" – that was a Canadian-owned Canadian corporation), "retroactive" to a particular date. ...

9 June 2005 Internal T.I. 2005-0115481I7 F- Avantages imposables/voyages-- summary under Paragraph 200(2)(g) Summary Under Tax Topics- Income Tax Regulations- Regulation 200- Subsection 200(2)- Paragraph 200(2)(g) T4As required to be issued to shareholder-employees of customers who were identifiable as receiving free trips – but not for sole proprietor customers The Corporation sells products to incorporated or unincorporated retailers, awards them dollar-amount points based on their volumes of purchases, with the retailers then rewarding their employees or shareholders (or themselves, if unincorporated) with trips that the Corporation paid for, with the dollar points accumulated in favour of the retailers being reduced accordingly. ...

31 August 2005 Internal T.I. 2005-0134831I7 F- Capital Gains Exemption Strip-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) the use of s. 40(3.6)(b) for surplus-stripping purposes would be referred to the GAAR Committee Two brothers, who had stepped up the ACB in shares of their respective holding companies using the capital gains exemption, then redeemed those preferred shares so as to give rise to a s. 84(3) deemed dividend and a capital loss which was denied and added to the ACB of their common shares of those holding companies pursuant to s. 40(6.2)(b) – then transferred those common shares to new Holdcos in exchange inter alia for preferred shares with a high ACB and PUC, which they then utilized on the redemption of those new preferred shares. ...